This document was prepared and published by the Memphis Metropolitan Planning Organization and is prepared in cooperation with financial assistance from all or several of the following public entities: the Federal Transit Administration, the Federal Highway Administration, th e Tennessee and Mississippi Department of Transportation, the Memphis Area Transit Authority, and the local governments in the MPO region.

It is the policy of the Memphis Urban Area Metropolitan Planni ng Organization (MPO) not to discriminate on the basis of age, sex, race, color, national origin or disability in its hiring or employment practices, or in its admission to or operation s of its program, services, or activities. All inquiries for Title VI and/or the American Disabilities Act, contact John Shaffer at 901-576-7130 or John.Shaffer@memphistn.gov. 

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M ARCH 20, 2013

M EMPHIS U RBAN A REA M ETROPOLITAN P LANNING O RGANIZATION

T RANSPORTATION P LANNING S ECTION

### T ABLE OF 

### C ONTENTS

1 Introduction .................................................................................................................. ............................................................. 3

1.1 Latest Planning Assumptions

............................................................................................................................ 4

1.2 Latest Emissions Estimation Model

................................................................................................................... 5

1.3 Interagency Consultation and Public Participation

........................................................................................... 5

1.4 Exempt Projects

............................................................................................................................... ................. 5

1.5 Conformity Test

............................................................................................................................... .................. 7
2 Methodology ................................................................................................................... .......................................................... 7

2.1 MOVES

............................................................................................................................... ................................ 8

2.2 Travel Demand Modeling

............................................................................................................................... ... 9
3 MOVES Runspec ................................................................................................................. ................................................... 12

3.1 Description

............................................................................................................................... ....................... 12

3.2 Scale

............................................................................................................................... ................................. 12

3.3 Time Spans

............................................................................................................................... ....................... 12

3.4 Geographic Bounds

............................................................................................................................... .......... 12

3.5 Vehicles/Equipment

............................................................................................................................... ......... 12

3.6 Road Type

............................................................................................................................... ......................... 12

3.7 Pollutants and Processes

............................................................................................................................... .. 13

3.8 Miscellaneous Strategies

............................................................................................................................... .. 13

3.9 Output

............................................................................................................................... .............................. 13
4 County Data Manager ........................................................................................................... .................................................. 13

4.1 Meteorology Data Importer

............................................................................................................................ 13

4.2 Source Type Population Importer

................................................................................................................... 13

4.3 Age Distribution Importer

............................................................................................................................... 14

4.4 Vehicle Type VMT and VMT Fractions

............................................................................................................. 14

4.5 Average Speed Distribution Importer

............................................................................................................. 14

4.6 Road Type Distribution Importer

.................................................................................................................... 15

4.7 Ramp Fraction Importer

............................................................................................................................... ... 15

4.8 Fuel Formulation and Fuel Supply Importer

................................................................................................... 15

4.9 Fueltype and Technologies Importer

.............................................................................................................. 15

4.10 Inspection and Maintenance (I/M) Importer

.................................................................................................. 15
5 Post-Processing of MOVES Output ............................................................................................... ......................................... 15

5.1 VMT and Source Type by County

.................................................................................................................... 16

5.2 Source Type Population Fraction and VMT Fraction

....................................................................................... 16

5.3 Hourly Distribution Fractions

.......................................................................................................................... 16

5.4 Road Type Distribution Fractions

.................................................................................................................... 16

5.5 Average Speed Distribution Fractions

............................................................................................................. 16

5.6 Aggregation Tables

............................................................................................................................... ........... 16
6 Summary Results and Conclusions ............................................................................................... ......................................... 17

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ii 

### L IST OF 

### T ABLES AND 

### F IGURES Table 1 – MOVES Runspec Parameters ............................................................................................ .................................................... 8 Table 2 – MOVES County Data Manager Parameters ................................................................................ ........................................... 8 Figure 1 - MPO and Travel Demand Model Boundaries ............................................................................. .......................................... 10 Table 3 – Annual VMT by Source Type by Year, DeSoto County Non-Attainment Area ................................................ ...................... 11 Table 4 – Summary of Total Mobile Source Emissions ............................................................................ ............................................ 18 Table 5 – Average NOx Emissions Rates by Source Type and Analysis Year ........................................................ ............................. 19 Table 6 – Total NOx Emissions (grams ) by Source Type and Analysis Year ........................................................ ............................... 19 Table 7 – Average VOC Emissions Rates by Source Type and Analysis Year ........................................................ ............................ 20 Table 8 – Total VOC Emissions (grams ) by Source Type and Analysis Year ........................................................ .............................. 20 

### L IST OF 

### E XHIBITS Exhibit 1 - Interagency Consultation Pre-Analysis Consensus Memorandum Exhibit 2 - 2011-2014 TIP and Memphis Urban Area 2040 LRTP Projects

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3 

### 1 Introduction As the number of vehicles on the nation’s roadways increased, air pollution from mobile sources was identified as an important national health concern. Recognizing this connection, the 1990 Clean Air Act Amendments (CAAAs) and the Mississippi Transpor tation Conformity Rules require transportation plans, programs (TIP), and projects to conform to the purpose of the Mississippi State Implementation Plan (SIP). Conformity to a SIP me ans that planned transportation activities will not produce new air quality violations, worsen existing violations, or de lay timely attainment of the national ambient air quality standards (NAAQS). The Transportation E quity Act for the 21st Century (TEA-21) and its successor legislations, the Safe, Accountable, Flexib le, Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU) and Moving Ahead for Progress in the 21 st Century (MAP-21) reinforce the need for coordinated transportation and air qua lity planning through the metropolitan planning provisions.

On May 21, 2012 the United States Environmenta l Protection Agency (EPA) designated the portion of DeSoto County, MS within the Memphis metropolit an area boundary as a marginal 8-hour ozone moderate non-attainment area (77 FR 30088). The 8-hour ozone area designation was effective on July 20, 2012. The State of Mississippi appealed this fi nding, but a ruling posted in 78 FR 925 (January 7, 2013) stated that appeal was formally denied by the EPA. The non-attainment portion of DeSoto County was classified as a marginal area, meaning they must reach attainment status within three years.

In July 2012, EPA issued the companion guidance 1 to the Conformity Rule that addresses ozone and air quality standards. The guidance further clarified how conformity determinations and the regional emissions analyses that support them are compl eted in existing and new non-attainment and maintenance areas. The guidance noted that states in a multi-state area have the option of submitting SIPs with budgets for just their own portion of the ar ea that, when taken togeth er, meet the applicable Clean Air Act requirement. Where states have done so and EPA has found such budgets adequate or approved, the MPO or MPOs in each state with such budgets can determine conformity completely independent of the other states. Furthermore, all affected agencies need to be included in the decisionmaking process for the area as required by §93.10 5 of the conformity rule. Shelby County, Tennessee and Crittenden County, Arkansas have budgets of th eir own. Since the portion of DeSoto County in non-attainment is classified as Marginal, it is not required to have a SIP budget. During the interagency consultation process, it was decided that DeSoto County would not be judged within the overall SIP budget established for Shelby County, but would in stead be subject to an independent conformity demonstration using the baseline test. Therefore, this conformity determination is only for the DeSoto County portion of the 8-hour oz one non-attainment area.

The purpose of this conformity analysis is to demonstrate that the partial DeSoto County nonattainment area supports the implementation of the financially constrai ned Direction 2040 Long Range Transportation Plan 2 (2040 LRTP) and the FY 2011-2014 Transportation Improvement Program (TIP) by contributing to improved ai r quality and will therefore not jeopardize DeSoto County’s attainment of the 2008 8-hour ozone NA AQS. The conformity determination has been performed according to procedures prescribed by th e following federal, state and local regulations: 69 FR 40004, 40 CFR Parts 51 and 93 (i.e. Trans portation Conformity Rule Requi rements); the Mississippi Transportation Conformity Rules; and Metropolit an Planning Organization (MPO) Planning

1 Guidance for Transportation Conformity Implementation in Multi-Jurisdictional Nonatta inment and Maintenance Areas, Transportation and Climate Divisi on Office of Transportation and Air Qua lity, U.S. Environmental Protection Agency (EPA-420-B-12-046).

2 Please refer to 2040 LRTP, Chapter 8 for the deta iled financial constraint aspect of the LRTP

.

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4 Regulations (23 CFR 450) implementing MAP-2 1 Requirements. Results of this conformity determination are found in Table 3 of this report. For each transportation plan (2040 LRTP), program (2011-2014 TIP), and FHWA/FTA project to be found to conform, the MPO and DOT must demonstrate that the applicable criteria and proced ures have been satisfie d (section §93.109-a). The following criteria for non-attainment areas are found to be applicable and are described as:

1) The TIP and LRTP must pass an emissions baseline test, comparing the conformity model years with a 2011 baseline value; 2) The conformity determinations must be base d upon the most recent planning assumptions; 3) The conformity determinations must be ba sed upon the latest emission estimation model available; 4) MPOs and state departments of transpor tation must provide reasonable opportunity for consultation with state air agencies, local air quality and transportation agencies, DOT, and the EPA; and 5) The conformity determination must comply with MAP-21 and MPO Planning Regulations.

This report documents the process used by the Memphis MPO for the Conformity Determination for the DeSoto County portion of the Memphis Urban Area MPO 2040 LRTP and the 2011-2014 TIP. Since this area has only been recently designated as non-attainment, this conformity determination represents the first time an air quality analysis has been performed. EPA’s MOVES2010b model was used to derive emission factors as required by the EPA 3 . The MOVES input files were created and modified as discussed in the interagency consulta tion process and laid out in the Pre-Analysis Consensus Memorandum (Exhibit 1). The emissions factors are based on a number of inputs including temperature, relative humidity, and presence of inspection and maintenance programs, vehicle source type mix, vehicle age distribution, temporal distri butions, and other roadway attributes. Emissions estimates are the product of aggregating the results from the emission rate development with average daily vehicle miles traveled (VMT), source type popu lations, hourly distribution, road type distribution, and average speed distribution.

The Memphis and Shelby County MPO Travel Dema nd Model was used to obtain VMT estimates. The Travel Demand Model was prepared with the conf ormity process in mind. For more information on the methodology and assumptions utilized in the de velopment of the Travel Demand Model, please refer to the Model Document ation (LRTP Appendix G).

1.1 Latest Planning Assumptions The Memphis and Shelby County MPO Travel Demand Model was developed with consultation and input from state and local transportation agenci es and the USDOT. The 2040 LRTP provides the appropriate level of detail required by 40 CFR 93 .106 of the conformity regulations. The highway projects in the 2040 LRTP are financially constraine d for the entire plan and for each horizon year in terms of capital, operations and maintenance costs (See LRTP Chapter 8 – Implementation Plan). The conformity analysis is based on assumptions derived from estimates of current and future population, employment, travel, and congestion. As part of the 2040 LRTP conformity determination, past assumptions have been discussed with various local, state and federal agencies for their continued validity and updated whenever necessary. Detailed pla nning assumptions are presented in Section 2 of this report.

3 Using MOVES to Prepare Emission Inventories in State Implementation Plans and Transportation Conformity: Technical Guidance for MOVES2010, 2010a, and 2010b, April 2012.

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5 1.2 Latest Emissions Estimation Model
Mobile source emissions estimates for the ozone season (summer) were developed using EPA's Motor Vehicle Emission Simulator, MOVES2010b (June 2012), and travel estimates from the latest Memphis MPO Travel Demand Model. The Memphis MPO, Mississippi Department of Transportation (MDOT), and Tennessee Department of Transporta tion (TDOT) provided the most current data available for emissions calculations. The Fede ral Highway Administration (FHWA) and EPA's Air Planning Branch in Atlanta provided assistance and guidance as well.

All of the projects in the 2011-2014 TIP are a subs et of the 2040 LRTP and as such include a program of projects, which is consistent with the scope of the 2040 LRTP in design and implementation schedule. Detailed project lists are presented in Exhibit 2.

1.3 Interagency Consultation and Public Participation Interagency consultation is the central coordinati ng mechanism for public agency involvement and input to the conformity determinati on. The conformity determination must be made according to 40 CFR §93.105-(a)-(2) and (e) and the requirements of 23 CFR 450 (40 CFR §93.112, Criteria and Procedures).

The Memphis MPO coordinated its activities for this conformity determination with numerous stakeholders and review agencies, including DeSo to County, Shelby County, Shelby County Health Department, Mississippi Department of Environmental Quality (M DEQ), Tennessee Department of Environment and Conservation (TDEC) Division of Air Pollution Control, MDOT, TDOT, FHWA, EPA, and other necessary agencies. The Memphi s MPO has held teleconference calls and email correspondence to discuss the issues pertinent to the DeSoto County Conformity Demonstration (e.g. latest planning assumptions). Verbal and written co mments from these calls and the meeting have been addressed (see Exhibit 1 - Interagency Consultation) . To more fully communicate the assumptions being made as a part of the conformity analysis , a preconsensus plan was developed for the ozone analyses. This document, titled “2040 DeSoto County Non-Attainment Area MOVES Air Quality Analysis Pre-Analysis Consensus Memorandum,” wa s reviewed by the interagency consultation group and modified based on comments received. This document is included in Exhibit 1.

The Memphis Urban Area MPO’s Public Participat ion Plan, adopted in 2007 and updated in 2011, specifies procedures to ensure public involvement in the planning process. All TPB and Engineering and Technical Committee (ETC), meetings are open to the public for comments on any item. The public was notified of the opportunities to comment on this conformity demonstration. All comments received from the public, committee members, and review agencies were addressed appropriately. Specific information related to the public partic ipation process for development of the LRTP is provided in Chapter 2 and Appe ndix A of the LRTP document.

1.4 Exempt Projects In evaluating the emissions impact of transporta tion activities in the conformity process, EPA regulations exempt certain projects included in a TIP or LRTP from anal ysis (see 40 CFR 93.126, 93.127, and 93.128). This decision is based on the assumption that these projects do not directly impact transportation related air emissions or that they may not be able to be precisely analyzed. The regulations identified two general categories of projects in the Transportation Conformity Reference Guide: 1) those exempt from regional emissions anal ysis; and 2) other highway and transit projects. In the regional exemption category, the following proj ects are specifically named and are considered by this report to be classified as exempt:

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6  Intersection channelization projects;

 Intersection signalization projects at individual intersections;

 Interchange reconfiguration projects;

 Changes in vertical or horizontal alignments;

 Truck size and weight inspection stations; and

 Bus terminals and transfer points.

The “other highway and transit project” list is longer and includes four primary categories: 1) safety, 2) mass transit, 3) air quality, and 4) other specific a ctivities which do not involve or lead directly to construction.

 Safety

o Railroad/highway crossing.

o Hazard elimination program.

o Safer non-Federal aid system roads.

o Shoulder improvements.

o Increasing sight distance.

o Safety improvement program.

o Traffic control devices and operating assistance other than signalization projects.

o Railroad/highway crossing warning devices.

o Guardrails, median barriers, crash cushions.

o Pavement resurfacing and/or rehabilitation.

o Pavement marking demonstration.

o Emergency relief (23 U.S.C. §125).

o Fencing.

o Skid treatments.

o Safety roadside rest areas.

o Adding medians.

o Truck climbing lanes outside the urbanized area.

o Lighting improvements.

o Widening narrow pavements or reconstructi ng bridges (no additional travel lanes).

o Emergency truck pullovers.

 Mass Transit

o Operating assistance to transit agencies.

o Purchase of support vehicles.

o Rehabilitation of transit vehicles.

o Purchase of office, shop, and operating equipment for existing facilities.

o Purchase of operating equipment for vehicl es (e.g., radios, fare boxes, lifts, etc.).

o Construction or renovation of power, signal, and communications systems.

o Construction of small passenger shelters and information kiosks.

o Reconstruction or renovation of transit buildin gs and structures (e.g., rail or bus buildings, storage and maintenance facilities, stati ons, terminals, and ancillary structures).

o Rehabilitation or reconstruction of track structure s, track, and track bed in existing rights-ofway.

o Purchase of new buses and rail cars to replace existing vehicles or for minor expansions of the fleet.

o Construction of new bus or rail storage/mainten ance facilities categorically excluded in 23 CFR part 771.

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7  Air Quality

o Continuation of ride-sharing and van-pooling promotion activities at current levels.

o Bicycle and pedestrian facilities.

 Other specific activities which do not involv e or lead directly to construction, such as:

o Planning and technical studies.

o Grants for training and research programs.

o Planning activities conducted pur suant to titles 23 and 49 U.S.C.

o Federal aid systems revisions.

o Engineering to assess social, economic, and envi ronmental effects of the proposed action or alternatives to that action.

o Noise attenuation.

o Emergency or hardship advance land acquisitions (23 CFR §710.503).

o Acquisition of scenic easements.

o Plantings, landscaping, etc.

o Sign removal.

o Directional and informational signs.

o Transportation enhancement activities (except rehabilitation and operation of historic transportation buildings, structures, or facilities).

o Repair of damage caused by natural disasters, civil unrest, or terrorist acts, except projects involving substantial functional, locational or capacity changes.

There are projects in the TIP and LRTP from each major category.

1.5 Conformity Test The conformity tests specified in the federal trans portation conformity rule are: (1) the emissions budget test, and (2) the emissions reduction test. For the emissions budget test, predicted emissions for the TIP/LRTP must be less than or equal to the motor vehicle emissions budget (MVEB) specified in the approved air quality implementation plan or the emissions budget found to be adequate for transportation conformity purposes. If there is no approved air quality plan for a pollutant for which the region is in non-attainment or no emission budget ha s been found to be adequate for transportation conformity purposes, the emissions reduction test applies. In the DeSoto County portion of the Memphis region, no MVEBs have been specified. As a result, the emissions reduction test has been used, with the year 2011 as the established baseline condition.



### 2 Methodology The emissions inventory development and emissions projection discussion below identifies procedures used by the Memphis MPO to obtain emission rates for the DeSoto County portion of the Memphis non-attainment area.

Table 1 summarizes the settings used in the MOVES run specification file. Table 2 lists the assumptions used in the MOVES County Data Manage r. Further details on the use of MOVES are found in the following sections.

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8 Table 1 – MOVES Runspec Parameters MOVES Runspec Parameter Settings MOVES2010b, Version 2012/04/10 Scale County, Emission Rates Time Span Time aggregation = Hour 1 month representing summer conditions (July) All hours of the day selected Weekdays only Geographic Bounds 1 custom domain – DeSoto County (partial) Vehicles/Equipment All valid source types, gasoline and diesel Road Type All road types including off-network Pollutants and Processes NO
x , VOCs, total gaseous hydrocarbons, non-methane hydrocarbons, methane General Output Units = grams, joules, miles Output Emissions Time = hour, location = link, on-roa d emission rates by road type and source use type Advanced Performance None

Table 2 – MOVES County Data Manager Parameters County Data Manager Input Data Source

Meteorology Data Local data from Memphis airport (MEM). Source Type Population Default data was used for all years. Age Distribution Local and default. Local data from motor vehicle registration data (classes 11, 21, and 31). Shelby County da ta (prepared by the University of Tennessee) applied for remaining vehicle source types. Vehicle Type VMT – HPMS Vehicle Type VMT Local data obtained from Memphis Travel Demand Model.

Vehicle Type VMT – Monthly VMT Fraction Determined using EPA conversion tool for Annual Average Weekly VMT.

Vehicle Type VMT – Daily VMT Fraction Determined using EPA conversion tool for Annual Average Weekly VMT.

Vehicle Type VMT – Hourly VMT Fraction Local data obtained from Memphis Travel Demand Model.

Average Speed Distribution Local data obtained from Memphis Travel Demand Model. Road Type Distribution Local data obtained from Memphis Travel Demand Model. Ramp Fraction Local data obtained from Memphis Travel Demand Model. Fuel Supply/Fuel Formulation Default Fueltype and Technologies Default I/M Programs No data entered.

2.1 MOVES The Clean Air Act (CAA) requires US EPA to regula rly update its mobile source emission models. US EPA continuously collects data and measures vehicl e emissions to make sure the Agency has the best possible understanding of mobile source emissions. This assessment, in turn, informs the development of US EPA’s mobile source emission models. MO VES represents the Agency’s most up-to-date assessment of on-road mobile source emissions. MOVE S also incorporates several changes to the US EPA’s approach to mobile source emission mode ling based upon recommendations made to the Agency by the National Academy of Sciences.

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9 The more detailed MOVES approach to modeling (when compared with the previous MOBILE model) allows US EPA to easily incorporate larg e amounts of in-use data from a wide variety of sources, such as data from vehicle inspection and maintenance (I/M) programs, remote sensing device (RSD) testing, certification testing, portable emission measurement systems (PEMS), etc. This approach also allows users to incorporate a variety of activity data to better estimate em ission differences such as those resulting from changes to vehicle speed an d acceleration patterns. MOVES has a graphical user interface which allows users to more easily set up and run the model. MOVES database-centered design provides users much greater flexibil ity regarding output choices. Unli ke earlier models which provided emission factors in grams-per-mile in fixed output formats, MOVES output can be expressed as total mass (in tons, pounds, kilograms, or grams) or as emission factors (grams-per-mile and in some cases grams-per-vehicle). Output can be easily aggregated or disaggregated to examine emissions in a range of scales, from national emissions impacts down to th e emissions impacts of individual transportation projects. The database-centered design also allows US EPA to update emissions data incorporated in MOVES more easily and will allow users to incorpora te a much wider array of activity data to improve estimation of local emissions. For example, the improvements in MOVES will allow project-level PM 2.5 emissions to be estimated.

2.2 Travel Demand Modeling The Memphis Urban Area travel demand model is the most recent and approved regional travel demand model for the study area. The travel dema nd model boundary includes all of DeSoto County and Shelby County, as well as portions of Tipton, Fayette, and Marshall Counties. Figure 1 shows the Memphis Urban Area and the Travel Demand Model bou ndaries. Although model approval is a joint process between the MPO and the appropriate state review agencies, the Tennessee Department of Transportation (TDOT) is the primary agency responsib le for approval of the travel demand model for use in developing the Long Range Transportation Pl an (LRTP) and other planning activities of the Memphis MPO. The travel demand model used for the air quality conformity analysis was reviewed and approved for use for long range plan and air quality conformity analysis purposes.

The Memphis Urban Area Travel Demand Model is a four step model. Trip generation, trip distribution, mode choice, and trip assignment com ponents are included in the model. The base year of the travel demand model is 2004 . Socioeconomic data was forecas ted to the year 2040 as a part of the most recent LRTP. Appendix G of the 2040 LRTP contains the assumptions and methodology used to develop the travel demand model.

Model Data Adjustments At the outset of this process, it was important to compare the information in the travel demand model to raw data obtained through traffic counts. The 2004 HPMS data was obtained from the Mississippi Department of Transportation (MDOT) for DeSoto County. The annual VMT shown in the HPMS data was compared to the total 2004 DeSoto Coun ty VMT shown in the travel demand model. This comparison yielded a HPMS/TDM ratio that was use d to scale the VMT output from the model to more closely match documented conditions. This scaled VMT was used in the development of the HPMS vehicle type VMT.

The adjusted annual vehicle miles traveled by MO VES vehicle source type for the study area are shown in Table 3.

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10 Figure 1

– MPO and Travel Demand Model Boundaries

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11 Table 3 – Annual VMT by Source Type by Year, DeSoto County Non-Attainment Area Source Type Source Type ID Source Type VMT

2004 2011 2015 2020 2030 2040

Motorcycle 11 3,549,769 4,366,366 5,417,479 6,291,863 8,219,229 10,364,090

Passenger Car 21 908,128,882 1,117,036,961 1,385,940, 627 1,609,632,022 2,102, 705,396 2,651,420,043

Passenger Truck 31 234,153,236 288,018,466 357,353,159 415,029,541 542,164,774 683,645,164
Light Commercial Truck 32 78,226,452 96,221,772 119,385,010 138,654,368 181,127,337 228,394,727

Intercity Bus 41 124,861 171,840 190,844 245,203 328,836 426,906

Transit Bus 42 71,569 88, 674 93,892 116,185 151,105 196,116

School Bus 43 866,640 1,164,182 1,281,946 1,635,150 2,173,136 2,821,145

Refuse Truck 51 573,769 558,584 486,423 458,960 416,971 454,262
Single Unit Short-haul Truck 52 30,964,500 40,102,032 43,657,439 55,254,691 73,266,162 95,173,627
Single Unit Long-haul Truck 53 2,906,325 5,326,845 6,396,981 8,666,568 11,825,266 15,361,526

Motor Home 54 6,845,732 9,348,650 10,310,066 13,166,575 17,538,768 22,784,227

Combination Shorthaul Truck 61 26,430,150 27,981,581 30,036,023 43,009,553 52,470,839 65,597,197
Combination Longhaul Truck 62 25,930,003 34,234,946 39,625,175 61,304,525 76,979,080 96,236,222

Total 1,318,771,889 1,624, 620,899 2,000,175,063 2,353,465,201 3,069, 366,897 3,872,875,252
Pre-Processing Information was gathered from the travel demand model to generate the average speed distribution, road type distribution, hourly VMT distribution, HP MS vehicle type VMT, and ramp fraction. To streamline this process, a pre-processor was devel oped. The pre-processor performed many of the calculations and disaggregations needed to prod uce MOVES-ready spreadsheets for each input. MOVES spreadsheet templates for each input type we re developed for the identified model years. Following this, a script was developed to pull the needed data from the model and perform any needed calculations. MOVES files generated through this ex ercise could then be applied directly in the County Data Manager. Additional information on the data sources used and needed data manipulation is contained in Sections 3 and 4.

Post-Processing The analysis was performed using the emission rates m ethod. As a result, post-processing of the data was required to arrive at the overall emissions output . To do this, the rate per distance and rate per vehicle output data were matched with the approp riate geographic area, analysis year, source types, pollutant types, road types, modeling hours, an d speed classes and then aggregated with the corresponding source type population and vehicle m iles traveled information. The resulting information was summarized by pollutant type for each full or partial county be ing analyzed to generate the overall emissions in tons per year. Sections 3 and 4 provide additional detail on the data sources gathered, modeling assumptions, and post-processing steps.

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12 

### 3 MOVES Runspec The MOVES2010b software was released by the En vironmental Protection Agency in July 2012. This software uses a graphical user interface with a set of input categories. A Runspec can be developed that stores the input values for these categories. The values and information included in the Runspecs developed for this analysis are explained in more detail in the following sections.

3.1 Description The information in this category is used to distinguish the individual Runspecs. For this analysis, the description is used to introduce the purpose for the analysis, the area being studied, and the year of analysis (i.e. 2004, 2011, 2015, 2020, 2030, and 2040).

3.2 Scale This input window is used to detail the information needed for the domain/scale of the analysis as well as the calculation type. The county level was selected as the domain for this effort, since it is the appropriate level for use in SIP and regional conf ormity analysis. The emission rate method was chosen for the calculation type. This calculat ion type was chosen following a discussion with the involved review agencies to determine the most appropriate calculation method for this analysis.

3.3 Time Spans The Time Spans input window has a variety of different timescale inputs that are used for understanding the level of temporal aggregation being used in the analysis. The time aggregation level was specified as hours, based on guidance from EP A/FHWA for the preferred aggregation level for conformity runs. Based on the interagency consulta tion process, the years 2004, 2011, 2015, 2020, 2030, and 2040 were chosen for the analysis years. Ea ch year was done within a different Runspec. Since the pollutant analysis being conducted is for the 8-hour ozone standard, July was chosen as the month to best represent summer conditions. Weekda ys were selected as the representative day type since they are considered to be the worst-case typ e when compared with weekends. All hours of the day were included in the analysis to repres ent conditions over a full 24-hour period.

3.4 Geographic Bounds This analysis consisted of a portion of DeSoto County. This input window also asks for the name of the domain input database. A total of six input da tabases were created during this process, reflecting the appropriate Runspec and input data for the analys is years 2004, 2011, 2015 , 2020, 2030, and 2040.

3.5 Vehicles/Equipment This input window allows the user to specify whic h fuel and vehicle types are present within the transportation network. There are thirteen different ve hicle classes (referred to as source use types) and five different fuel types. This analysis considers the diesel and gas fuel types only. This was partly to reflect the lack of compressed natural gas and liquefied petroleum gas vehicles in the population, and also to allow for default fuel formulation and fuel supply information to be used in the study area. Within this, all possible vehicle and fuel types were considered. Diesel motorcycles, gas combination long-haul trucks, and gas intercity buses were remove d since they are not represented in the vehicle population.

3.6 Road Type The MOVES software incorporates fi ve different roadway types: o ff-network, rural restricted access, rural unrestricted access, urban restricted access, and urban unrestricted access. Expressways and

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13 freeways in the region are considered as restricted acce ss facilities. For this analysis, all five vehicle types were considered. Off-network emissions are intended to account for vehicle starts and evaporative emissions for parked vehicles. While these emissions are not captured through the information in the regional travel demand models, default values can be used to assess their impacts.

3.7 Pollutants and Processes This input window allows the user to specify diffe rent pollutants and proce sses that are desired for modeling. Since the purpose of this analysis is to assess emissions relating to the 8-hour ozone standard, the interagency consultation specified the inclusion of Oxides of Nitrogen (NO
x ), Volatile Organic Compounds (VOC), Non-Methane Hydrocarbons (NMHC), Total Gaseous Hydrocarbons (THC), and Methane (CH 4 ).

3.8 Miscellaneous Strategies The MOVES software includes input windows where pr ovisions can be specified for specific strategies such as on-road retrofit and rate of progress emissions. Since these stra tegies are not being applied in this location, no information was entered for this section.

3.9 Output Output for the MOVES program is stored in a user- created database. Output databases were created for each of the 6 different Runspec conditions. As specified in the interagency consultation process, grams, joules, and miles were used as the units of measure in the output database. Based on the parameters already established in these Runspecs, th e time measurement for this analysis was set as hourly, and the location was automatically set for the link level. To assist with post-processing aggregation, it was further requested that the source use type information be included with the output.



### 4 County Data Manager Once all of the base parameters have been estab lished for a given MOVES Runspec, the County Data Manager can be used to enter locally-specific data. Input provided in Excel spreadsheet format can be referenced using this tool, which converts the data to MySQL format and incorporates it into the MOVES analysis. For the DeSoto County portion of the non-attainment area, locally-specific data could consist of data used for the entire region, st atewide, or county-level data. The following sections detail these input criteria, and th e methodology and assumptions used to arrive at the information entered for each.

4.1 Meteorology Data Importer Meteorological data for the analysis area was obtained from the Shelby County MOVES run conducted in late 2011. This data was colle cted at the Memphis International Airport and is assumed to be applicable for the DeSoto County non-attainment area as well as all analysis years.

4.2 Source Type Population Importer This importer provides the user with the opportunity to enter vehicle population da ta sorted by the 13 MOVES vehicle source types. The Pre-Analysis Consensus Memorandum indicated that DeSoto County data would be referenced where possible. Whe n this data was analyzed, it was determined that inconsistencies in the vehicle type definitions were significant enough that the data set as a whole could not be used. Statewide data sources were also cons idered for use, particularly for trucks. However, these data are available only at the statewide level, not at the county level. As a result, default data was used as a starting point for all source types. Th e MOVES Technical Guidance offers guidance on how to leverage default population and VMT data alongside local VMT data to arrive at an estimate of the

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14 local population. This methodology was applied for all analysis years. A growth rate was not applied, since growth is inherently built in through this methodology.

4.3 Age Distribution Importer The Age Distribution Importer allows the user to prov ide vehicle age distribution data sorted by the MOVES vehicle source types. Vehicle age distributi on is divided into 30 years based on vehicle model years. For each vehicle type, the sum of all age distributions will equal one. DeSoto County registration data was able to be used for motorcycl es, passenger cars, and passenger trucks. For the remainder of source types, data was obtained from a study conducted by th e University of Tennessee – Knoxville. This data was specific to Shelby Coun ty, and as such can be reasonably transferred to DeSoto County.

4.4 Vehicle Type VMT and VMT Fractions This data importer asks the user for the VMT in the study area by HPMS vehicle class type, hourly VMT distributions, daily VMT distributions, and mont hly VMT distributions. The HPMS vehicle class VMT is asked for an annual basis. To determine th is information, data can be pulled from available travel demand models or from regional HPMS data.
HPMS Vehicle Class VMT The HPMS vehicle class VMT was determined using the pre-processor developed within the travel demand model. The travel demand model classifies vehicles into automobiles, single unit trucks, and combination unit trucks. The three vehicle classes in the model were divided into the six HPMS vehicle class types through the pre-processor. Sin ce the travel demand model produces daily weekday volumes, the EPA conversion tool was used to conv ert these daily VMT numbers to annual values. Daily VMT Fraction
The EPA conversion tool for Annual Average Weekday Vehicles Miles Traveled was used to determine the daily VMT fraction for each analysis year. Monthly VMT Fraction
The EPA conversion tool for Annual Average Weekday Vehicles Miles Traveled was used to determine the daily VMT fraction for each analysis year. Monthly VMT fractions are different on leap years (2004, 2020, and 2040) than on non-le ap years (2011, 2015, and 2030). Hourly VMT Fraction The hourly VMT fraction was determine d using the pre-processor develo ped within the travel demand model. To produce the information needed for the MOVES input file, the three vehicle classes in the model were expanded to the 13 MOVES vehicle source typ es. In addition, the four time of day periods in the model were expanded to represent each hour of the day. The default mix of off-network hourly distribution percentages was used for all vehicle classes.

4.5 Average Speed Distribution Importer This importer gives the user the opportunity to enter locally specific average speed data, disaggregated by vehicle source type, road type, weekday/weekend, and hour of the day. The MOVES model uses 16 speed bins, dividing speed distributions into a fracti on of driving within each speed bin for each of the criteria listed previously. The average speed di stribution was determined using the pre-processor developed within the travel demand model. The vehicle classes in the model were expanded to the 13 MOVES vehicle source types, and the hourly distribution was expanded from the four time periods in the model to each hour of the day.

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15 4.6 Road Type Distribution Importer The road type distribution importer can be used to incorporate locally-specific roadway distribution information. The average speed distribution was d etermined using the pre-processor developed within the travel demand model. The vehicle classes in the model were expanded to the 13 MOVES vehicle source types.

4.7 Ramp Fraction Importer This importer allows the user to input the percentage of traffic on urban restricted and rural restricted roadways that is traveling on ramp facilities. The ramp fractions were determined using the preprocessor developed within the travel demand model.

4.8 Fuel Formulation and Fuel Supply Importer The fuel formulation and fuel supply importers are used to input locally-specific fuel properties into the model. The pre-analysis consensus memorandum speci fied that default values would be used for this category.

4.9 Fueltype and Technologies Importer This importer value considers the alternative vehicl e fuels and technologies (AVFT). If no information is entered for AVFT, MOVES assumes a default mix of alternative fuels. The MOVES default mix assumes a small percentage of compressed natura l gas (CNG) transit buses. Since there are no alternative fuel vehicles in the transit fleet for De Soto County, the default value for this file was modified to reflect only diesel and gasoline fuel types.

4.10 Inspection and Mainte nance (I/M) Importer This importer would allow local inspection and maintenance data to be entered for the study area. The DeSoto County portion of the non-attainment area has no I/M program in place. When default data is exported for this, the file indicates there are no I/M programs in place for the area. Since this is an accurate representation of the I/M program in the area, no further data was entered.



### 5 Post-Processing of MOVES Output Once the appropriate data was input into the MOVES Runspecs and the County Data Manager, the six scenarios were run using the MOVES program. The following MOVES output databases were produced:

 DeSoto_2004

 DeSoto_2011

 DeSoto_2015

 DeSoto_2020

 DeSoto_2030

 DeSoto_2040

Since the emission rates method was used for this analys is, only two tables within each output database are used. The tables are called rateperdistance and ratepervehicle. Ultimately, information from both tables was used to determine overall emissions, a ggregating the information for the running emissions (rateperdistance) and idling emissions (ratepervehicle).

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16 The rateperdistance and ratepervehicle tables all re present scenarios for one geographic area (DeSoto County), one analysis year (2004, 2011, 2015, 2020, 20 30, or 2040), one month (July), and one day type (weekdays). Results within the rateperdistance tables are disaggregated by hour of the day, pollutant type, process type, vehicle source type, roadway type, and speed category. Temperature and relative humidity data vary by the hour of the day. Results within the ratepervehicle tables are disaggregated by hour of the day, pollutant type, pr ocess type, and vehicle source type. Temperature data within these tables varies by the hour of the day.

The final output desired for this analysis summarizes the total emissions by pollutant type for each analysis year and geographic area. As a result, the information contained in each scenario’s rateperdistance and ratepervehicle ha s to be matched with corresponding vehicle miles traveled (VMT) and source population data. To do this, a set of suppor ting tables were created that match these criteria with information contained in the rateperdistance and ratepervehicle tables such as vehicle source types, road types, speed categories, and hour of the day. Th e creation of those tables and the process used to calculate total emissions are detailed in the subsequent sections.

5.1 VMT and Source Type by County This table displays the daily and annual VMTs an d the source type population for all of the counties and analysis years in this effort. The daily VMTs were pulled for each area from the spreadsheets used to develop the HPMS vehicle type VMTs. Annual VMTs for each county were determined using the EPA converter spreadsheet.

5.2 Source Type Population Fr action and VMT Fraction This table separates the vehicle population into the different source types, and then determines the fraction of the population represente d in each type as well as the fra ction of total VMT represented in each type. The source type populations were pulled from the adjusted default data used for the MOVES runs. Within the MOVES format, VMTs wer e gathered by the six HPMS vehicle classes rather than the 13 MOVES source types. As a result , a translation was needed to match the appropriate HPMS vehicle classes with the MOVES source types . One the two classification types were matched to one another, the source type fractions estab lished based on the vehicle populations were used to factor VMTs of different source type classifications th at fell within the same HPMS vehicle class.

5.3 Hourly Distribution Fractions This table provides the hourly VMT fractions, separa ted by source type, road type, hour of the day, and state. Hourly distribution fractions were pulled from the table created for use in the MOVES program.

5.4 Road Type Distribution Fractions This table provides the road type VMT fractions sepa rated by vehicle source types. Road type fractions were pulled directly from the MOVES input file developed earlier.

5.5 Average Speed Distribution Fractions This table provides the average speed fraction sorted by source type, road type, hour of the day, and speed class. This file is the same as the MO VES input file used earlier in this analysis.

5.6 Aggregation Tables Once the supporting tables were created, the informati on within them needed to be combined in a way that matched the independent variables shown in the rateperdistance and ratepervehicle tables. Due to

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17 the large number of records and computations required to perform this exercise, some sort of advanced database and/or scripting tool was necessary. Since the Memphis Urban Area Travel Demand Model is operated in the TransCAD platform, it was determine d that a programming script developed and run in TransCAD would be an effective wa y to summarize this information.

In an effort to create a step within this scriptin g process that could later be referenced and checked, two intermediate tables were developed. The tabl es developed were designated as the VMT Summary Table and the Source Type Population Summary Ta ble. Each table’s intent and composition is described below, along with an example of the information produced within the tables.

VMT Summary Table The VMT Summary Table contains many of the same independent variables found in the rateperdistance output tables; namely, state, analysis year, source type, road typ e, hour of the day, and average speed bin. This table further divides the info rmation by the individual counties in the analysis. The intent of this table is to determine the proporti on of daily and annual VMT for a given county and analysis year that is represented within each combin ation of vehicle source type, road type, hour of the day, and speed category. This table references the source type VMT fraction generated in the Source Type Population Fraction and VMT Fraction table, th e road type VMT fraction generated in the Road Type Distribution table, the hour VMT fraction gene rated in the Hourly Distribution Fraction table, and the average speed fraction from the Average Speed Distribution Fra ction table. These four values are multiplied together to determine an overall fra ction, which is then multiplied by the corresponding daily and annual VMT established in the VMT and Source Type table. When the daily VMT proportions and annual VMT proportions are summed for a particular county and analysis year combination, they will equal the corresponding VMT valu es shown in the VMT and Source Type table.

Source Type Population Summary Table The Source Type Population Summary Table contains many of the same independent variables found in the ratepervehicle output tables; namely, state, an alysis year, source type, road type, and hour of the day. This table further divides the information by th e individual counties in the analysis. The intent of this table is to determine the proportion of the so urce type population for a given county and analysis year that is represented within each combination of ve hicle source type, road type, and hour of the day. This table references the source type population fra ction generated in the Source Type Population and VMT Fraction table and the hour VMT fraction generated in the Hourly Distribution Fractions table. These two values are multiplied together to get an overall fraction, which is then multiplied by the corresponding source type population information found in the VMT and Source Type table. The population proportion should be equal to the corresponding source type population value shown in the VMT and Source Type table.



### 6 Summary Results and Conclusions As mentioned in the previous section, a TransCAD script was developed to quickly match the information in the rateperdistance and ratepervehicl e tables with correspondi ng VMT and source type population information. This script also summed th e matched information by county, analysis year, and pollutant type to create the final output format need ed for this process. Results from this script are produced in a form that is easily formatted to show the overall emissions information contained in the main body of this report.

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18 Results from this analysis are summarized in Table 4 . Additional detail on th e average emission rates and total emissions has been provided in Tables 5 through 8 . These tables break out emission rates and emissions for each analysis year by the 13 MOVES vehicle source types. Results from the rateperdistance analysis were averaged over all road types, hours of the day, and speed bins to obtain these values. Results from the ratepervehicle anal ysis were averaged over all hours of the day.

Table 4 – Summary of Total Mobile Source Emissions

Pollutant Emissions (tons/day)
2011* 2015 2020 2030 2040 Volatile Organic Compounds (VOC) 2.256 1.790 1.179 1.064 1.384 Oxides of Nitrogen (NO
x ) 6.953 5.356 3.662 2.697 3.143 *Baseline analysis year

2011 was identified through the interagency consultation process as the baseline year for this analysis. Based on the results from the MOVES analysis, each subsequent model year exhibits a reduction in emissions in both VOCs and NOx.

The analysis indicates that the projected emissions levels based on projects contained in the Memphis Urban Area 2040 Long Range Transportation Plan (2040 LRTP) and FY 2011-2014 Transportation Improvement Program (TIP) meet the applicable conf ormity tests. It is the determination of this analysis that the FY 2011-2014 TIP and the 2040 LRTP conform under the 2008 8-hour ozone National Ambient Air Quality Standards.

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19 Table 5 – Average NO
x Emission Rates by Source Type and Analysis Year Source Type Source Type ID Analysis Year

2004 2011 2015 2020 2030 2040

A

verage Emission Rate Per Distance Traveled Motorcycle 11 0.99 0.67 0.59 0.54 0.52 0.51 Passenger Car 21 1.90 1.02 0.62 0.31 0.13 0.11 Passenger Truck 31 3.30 1.96 1.28 0.76 0.42 0.38 Light Commercial Truck 32 3.46 1.93 1.27 0.83 0.58 0.56 Intercity Bus 41 28.35 16.88 10.38 5.05 2.00 1.81 T ransit Bus 42 27.49 15. 11 8.78 4.14 1.78 1.67 School Bus 43 15.17 10.93 8.07 5.23 2.09 1.30 Refuse Truck 51 21.56 9.93 5.56 3.17 1.85 1.70 Single Unit Short-haul Truck 52 11.31 6.29 4.02 2.72 1.92 1.81 Single Unit Long-haul Truc k 53 11.14 6.57 4. 34 2.91 1.92 1.77
Motor Home 54 8.98 6.65 5.25 4.05 2.79 2.38 Combination Short-haul Truc k 61 25.97 11.83 6. 53 3.62 2.03 1.85 Combination Long-haul Truck 62 28.17 13.45 7.73 4.31 2.21 1.94 A

verage Emission Rate Per Vehicle Motorcycle 11 0.00 0.00 0.00 0.00 0.00 0.00 Passenger Car 21 0.46 0.37 0.28 0.18 0.10 0.08 Passenger Truck 31 0.80 0.64 0.47 0.29 0.12 0.09 Light Commercial Truck 32 0.71 0.46 0.32 0.19 0.10 0.09 Intercity Bus 41 0.00 0.00 0.00 0.00 0.00 0.00 T ransit Bus 42 0.01 0. 01 0.01 0.01 0.00 0.00 School Bus 43 0.42 0.15 0.08 0.04 0.01 0.01 Refuse Truck 51 0.04 0.02 0.02 0.01 0.01 0.00 Single Unit Short-haul Truck 52 0.78 0.46 0.32 0.20 0.06 0.03 Single Unit Long-haul Truc k 53 0.36 0.21 0. 15 0.09 0.03 0.01
Motor Home 54 0.12 0.07 0.05 0.03 0.01 0.00 Combination Short-haul Truc k 61 0.02 0.01 0. 00 0.00 0.00 0.00 Combination Long-haul Truck 62 16.65 14.22 16.80 17.81 22.59 25.42

Table 6 – Total NO
x Emissions (grams) by Source Type and Analysis Year Source Type Source Type ID Analysis Year

2004 2011 2015 2020 2030 2040
Motorcycle 11 9,607 8,073 8,444 9,261 11,085 13,322 Passenger Car 21 3,649,503 2, 502,888 2,001,985 1, 162,272 724,622 779,818 Passenger Truck 31 1,704,909 1,264,167 1,056,109 693,223 507,901 590,677 Light Commercial Truck 32 490,893 337,035 293,522 211,795 212,397 278,278 Intercity Bus 41 6,843 6,023 4,111 2,218 1,277 1,532 T ransit Bus 42 3,059 2,125 1,559 848 484 589 School Bus 43 22,192 21,782 18,203 14,520 7,917 6,714 Refuse Truck 51 25,135 10,837 5,358 2,865 1,561 1,637 Single Unit Short-haul Truck 52 578,272 429,755 313,753 272,283 278,187 356,255 Single Unit Long-haul Truc k 53 52,384 58,617 48, 673 45,042 44,839 56,077
Motor Home 54 117,047 118,236 105,361 103,509 100,713 116,520 Combination Short-haul Truck 61 1,368,611 639,336 384, 719 291,033 205,787 245,154 Combination Long-haul Truck 62 1,476,650 908,646 617,034 513,662 349,505 404,732
T otal NO
x Emissions 9,505,103 6,307,521 4,858,832 3,322,532 2,446,275 2,851,305

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20 Table 7 – Average VOC Emission Rates by Source Type and Analysis Year Source Type Source Type ID Analysis Year

2004 2011 2015 2020 2030 2040

A

verage Emission Rate Per Distance Traveled Motorcycle 11 4.64 3.41 3.11 2.87 2.68 2.66 Passenger Car 21 1.55 0.63 0.36 0.20 0.12 0.11 Passenger Truck 31 2.47 1.06 0.63 0.33 0.18 0.17 Light Commercial Truck 32 1.56 0.64 0.38 0.23 0.16 0.15 Intercity Bus 41 1.56 1.29 0.91 0.44 0.18 0.16 T ransit Bus 42 1.77 1. 43 0.98 0.43 0.18 0.17 School Bus 43 2.70 1.58 1.10 0.72 0.33 0.22 Refuse Truck 51 1.54 0.94 0.59 0.39 0.28 0.26 Single Unit Short-haul Truck 52 2.32 1.38 1.00 0.76 0.61 0.59 Single Unit Long-haul Truc k 53 2.43 1.51 1. 12 0.84 0.66 0.63
Motor Home 54 4.22 2.87 2.38 1.91 1.49 1.40 Combination Short-haul Truc k 61 1.59 0.96 0. 56 0.32 0.19 0.17 Combination Long-haul Truck 62 1.52 0.99 0.60 0.36 0.20 0.18 A

verage Emission Rate Per Vehicle Motorcycle 11 0.16 0.16 0.11 0.08 0.05 0.05 Passenger Car 21 0.84 0.61 0.48 0.36 0.28 0.27 Passenger Truck 31 1.25 0.97 0.71 0.46 0.27 0.24 Light Commercial Truck 32 0.87 0.57 0.41 0.28 0.18 0.17 Intercity Bus 41 0.00 0.00 0.00 0.00 0.00 0.00 T ransit Bus 42 0.01 0. 01 0.01 0.00 0.00 0.00 School Bus 43 0.40 0.16 0.08 0.04 0.02 0.01 Refuse Truck 51 0.05 0.04 0.03 0.02 0.01 0.01 Single Unit Short-haul Truck 52 0.65 0.43 0.31 0.21 0.10 0.07 Single Unit Long-haul Truc k 53 0.54 0.36 0. 27 0.18 0.09 0.07
Motor Home 54 0.34 0.29 0.23 0.16 0.07 0.06 Combination Short-haul T ruck 61 0.03 0.01 0.00 0.00 0.00 0.00 Combination Long-haul Truck 62 5.99 3.38 3.17 2.81 3.17 3.50

Table 8 – Total VOC Emissions (grams) by Source Type and Analysis Year Source Type Source Type ID Analysis Year

2004 2011 2015 2020 2030 2040
Motorcycle 11 26,572 23,385 27,655 27,510 36,617 50,740 Passenger Car 21 2,228,579 1,153,969 893,859 560, 478 496,918 644,140 Passenger Truck 31 948,217 546,426 439,307 263,905 205,836 254,601 Light Commercial Truck 32 202,642 108,962 87,958 58,587 57,459 78,676 Intercity Bus 41 275 331 264 143 100 125 T ransit Bus 42 160 160 139 71 45 57 School Bus 43 3,322 2,600 2,052 1,622 1,119 1,082 Refuse Truck 51 1,339 775 456 287 211 240 Single Unit Short-haul Truck 52 101,894 77,955 64,209 57,094 67,520 96,746 Single Unit Long-haul Truc k 53 9,905 11,405 10, 609 10,161 11,928 16,778
Motor Home 54 41,113 39,333 37,672 36,515 40,944 56,190 Combination Short-haul Truc k 61 55,310 34,700 23, 743 19,577 16,761 20,653 Combination Long-haul Truck 62 56,085 46,916 36,296 33,773 29,368 35,648
T otal NO
x Emissions 3,675,416 2,046,917 1,624,219 1,069,723 964,828 1,255,675